St. Anne's Hospital v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Segunda and Monico Manglicmot filed a claim for death compensation and burial expenses for their son, Federico Manglicmot, who was employed by St. Anne's Hospital as a Maintenance Man from November 1, 1969, to April 1, 1972. Federico Manglicmot was diagnosed with "Congestive Heart Failure secondary, Rheumatic Heart Disease" in March 1972, while still employed. He continued to receive treatment and was eventually confined at the La Union Provincial Hospital from September 9, 1972, to October 31, 1972. He passed away on May 24, 1973, due to "Congestive Rheumatic Heart Disease." Procedural History: The claim was filed with the Workmen's Compensation Section, Regional Office No. 4, Department of Labor. The petitioner, St. Anne's Hospital, controverted the claim, arguing the absence of an employer-employee relationship, that Federico Manglicmot had resigned, and that the claim was barred by laches. The Acting Referee ruled in favor of the claimants. The petitioner appealed to the Workmen's Compensation Commission, which affirmed the referee's decision. The Petition: St. Anne's Hospital filed a petition for review with the Supreme Court, assailing the decision of the Workmen's Compensation Commission. The petitioner argued that there was no employer-employee relationship, that the claim was barred by laches, and that the decision was a nullity for having been rendered without hearing and without affording the petitioner an opportunity to be heard.
Issue(s)
Whether the illness of Federico Manglicmot is compensable under the Workmen's Compensation Act. Whether an employer-employee relationship existed between Federico Manglicmot and St. Anne's Hospital at the time the illness supervened. Whether the claim for compensation is barred by laches or prescription. Whether the petitioner was denied procedural due process.
Ruling
The petition is dismissed, and the decision of the Workmen's Compensation Commission is affirmed. The claimants, Segunda and Monico Manglicmot, are awarded death compensation and burial expenses. Atty. Crisanto Hypaur is awarded attorney's fees, and the Commission is awarded administrative costs.
Ratio Decidendi
On Issue 1: The Supreme Court held that the illness of Federico Manglicmot is presumed to be compensable because it supervened during his employment with St. Anne's Hospital. The Court emphasized that it is not required for the employment to be the sole factor in the development or acceleration of the illness; it is sufficient that the employment contributed even in a small degree. The petitioner failed to rebut this presumption. On Issue 2: The Court found that an employer-employee relationship existed. The Director of St. Anne's Hospital certified that Federico Manglicmot was employed from November 1, 1969, up to April 1, 1972. The illness contracted in March 1972 occurred while he was still employed, and his resignation was to be effective April 1, 1972. Therefore, the sickness supervened in the course of employment. On Issue 3: The Court ruled that the claim is not barred by laches or prescription. It reiterated that the defense of prescription is not jurisdictional and that the statutory right to compensation prescribes in ten years, as provided by Article 1144(2) of the New Civil Code. The claim was filed within this period. On Issue 4: The petitioner was not denied procedural due process. The Court noted that the petitioner was present during hearings before the Acting Referee, the claimants' affidavits were open for inspection, and the petitioner was served a copy of the Acting Referee's decision, which allowed them to appeal to the Workmen's Compensation Commission.
Main Doctrine
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, holding that the illness of Federico Manglicmot, which led to his death, was presumed to be compensable as it supervened during his employment with St. Anne's Hospital. The Court found that the petitioner failed to rebut this presumption and that the claim was not barred by prescription. Procedural due process was also deemed to have been observed, as the petitioner was given opportunities to be heard and to appeal.